NPDES

Best Management Practices GUIDANCE DOCUMENT

Environmental Protection Agency Office of Water Enforcement and Permits

NPDES Technical Support Branch

June 1981

CONTENTS

Page No.

Preface ..................................... i

Abstract ..................................... ii

I. Introduction................................... 1

Background ............................... 1

Statutory Authority ....................... 2

BMP Regulatory History ................... 3

Final BMP Regulation ..................... 4

Final Guidance Document ................... 5

II. Use of the Guidance Document ................... 6

III. BMP Plans ..................................... 7

Scope ..................................... 7

Minimum Requirements ..................... 9

General Requirements ..................... 11

Specific Requirements ..................... 11

1. BMP Committee........................ 12

2. Risk Identification and Assessment .. 14

3. Reporting on BMP Incidents .......... 18

4. Materials Compatibility .............. 20

5. Good Housekeeping.................... 22

6. Preventive Maintenance .............. 23

7. Inspection and Records .............. 24

8. Security ............................ 28

9. Employee Training.................... 30

PREFACE

During the period June 13, 1978, to February 26, 1979,

Hydroscience, Inc., under Contract No. 68-03-2568 to the Environmental

Protection Agency (EPA), gathered information leading to the

identification of best management practices (BMPs) currently used by

industry. The result of the data gathering and analysis by

Hydroscience, Inc., was a draft report entitled "NPDES Best Management

Practices Guidance Document" EPA 600/9-79-045. In response to keen

public interest in the draft report, EPA made the report available to

the public and provided a 45-day comment period. The comment period

subsequently was extended twice, resulting in a total 120-day comment

period on the report. After evaluating the comments received, EPA

revised the draft report, and published this final document. This

document supersedes the Hydroscience draft report dated December 1979.

i

ABSTRACT

The purpose of this document is to assist National Pollutant

Discharge Elimination System (NPDES) permitting authorities, compliance

officers and permit applicants to develop Best Management Practices

(BMP) plans for industry. BMPs are authorized under the 1977 Clean

Water Act for the control of discharges to receiving waters of

significant amounts of any pollutant listed as hazardous under Section

311 of the Act or toxic under Section 307 of the Act from activities

which are associated with or ancillary to industrial manufacturing or

treatment processes. The general types of discharges to be controlled

by BMPs are plant site runoff, spillage and leaks, sludge and waste

disposal, and drainage from material storage areas.

This document provides a basis for developing BMP plans. The

proper sue of the document requires engineering experience with

industrial manufacturing and treatment processes and knowledge of

current laws and regulations applicable to NPDES permits, BMP plans, and

Spill, Prevention, Control and Countermeasure (SPCC) plans.

The guidance herein is based on a review by Hydroscience, Inc.

(EPA Contract No. 68-03-2568) of current practices used by industry to

control the non-routine discharge of toxic pollutants and hazardous

substances. Included in the review are published articles and reports,

technical bulletins (also termed material safety data sheets) on

specific compounds, and discussions with industry through telephone

contacts, written questionnaires, and site visits.

ii

SECTION I

INTRODUCTION

Background

The Federal Water Pollution Control act Amendments of 1972

established the objective of restoring and maintaining the chemical,

physical, and biological integrity of the Nation's water. This

objective has remained unchanged in the 1977 amendments to the Act,

commonly referred to as the Clean Water Act of 1977, hereinafter "the

Act". To achieve this end, the Act sets forth a series of goals,

including the goal of eliminating the discharge of pollutants into

navigable waters by 1985. The principal mechanism for reducing the

discharge of pollutants from point sources is through implementation of

the National Pollutant Discharge Elimination System (NPDES) established

by Section 402 of the Act.

At the time of first round NPDES permit issuance, conventional

pollutants (BOD, pH, TSS, etc.) were considered the parameters which

most urgently needed controls. In second round permitting, however, the

Agency emphasis is shifting from the conventional pollutants to the

control of toxic pollutants and hazardous substances.

Traditionally, NPDES permits have contained chemical-specific

numerical effluent limits. Effluent guidelines are not always available

to prescribe these effluent limits nor to guarantee water quality

sufficient for the protection of indigenous aquatic life. To improve

water quality, the Act provides for water pollution controls

supplemental to effluent limitations guidelines. Best Management

Practices (BMPs) are one such supplemental control.

Pursuant to Sections 304 and 402 of the Act, BMPs may be incorporated as

permit conditions. In the context of the NPDES program, BMPs are

actions or procedures to prevent or minimize the potential for the

release of toxic pollutants or hazardous substances in significant

amounts to surface waters. BMPs, although normally qualitative, are

expected to be most effective when used in conjunction with numerical

effluent limits in NPDES permits.

Statutory Authority

Section 304(e) of the Act authorized the Administrator to publish

regulations to control discharges of significant amounts of toxic

pollutants listed under Section 307 or hazardous substances listed under

Section 311 from activities which the Administrator determines are

associated with or ancillary to industrial manufacturing or treatment

processes. The discharges to be controlled by BMPs are plant site

runoff, spillage or leaks, sludge or waste disposal and drainage from

raw material storage.

Section 402(a)(1) of the Act allows the Administrator to prescribe

conditions in a permit determined necessary to carry out the provisions

of the Act. BMPs are one such condition.

BMPs are intended to complement other regulatory requirements

imposed by RCRA, OSHA, the Clean Air Act, and SPCC plans for hazardous

substances under the Clean Water Act. Pursuant to Section 311 of the

Act, EPA has proposed (40 CFR Part 151) requirements for SPCC plans to

prevent discharges of hazardous substances from facilities subject to

NPDES permitting requirements.

2

The guidelines proposed for hazardous substances SPCC plans are very

similar to those required for oil SPCC plans in the Oil Pollution

Prevention Regulations, (40 CFR Part 112). Since the Agency has

received favorable comments about the Oil Pollution Prevention

Regulations, the NPDES BMP regulation has been structured to be similar

to the oil SPCC regulation.

BMP Regulatory History

On September 1, 1978, EPA proposed regulations (43 FR 39282)

addressing the use of procedures to control discharges from activities

associated with or ancillary to industrial manufacturing or treatment

processes. The proposed rule indicated how best management practices

would be imposed in NPDES permits to prevent the release of toxic and

hazardous pollutants to surface waters. The proposed regulation was

incorporated as "40 CFR Part 125, Subpart L - Criteria and Standards for

Best Management Practices Authorized Under section 304(e) of the Act" in

the August 21, 1978 proposed NPDES regulations (43 FR 37078). A 60-day

comment period on proposed Subpart L was provided.

After evaluating the comments received on the proposed regulation,

EPA revised Subpart L and promulgated the regulation as Subpart K (44 FR

32954-5) on June 7, 1979. Industries regulated by Subpart K were to

develop a BMP program and submit the program with their permit

application. Subpart K stated that information on the development of

BMP programs was contained in a publication entitled "NPDES Best

Management Practices Guidance Document." Subpart K was to become

effective on August 13, 1979. However, publication of the report was

delayed beyond August 13, 1979.

3

Therefore, on August 10, 1979, EPA deferred applicability of the BMP

portions of the NPDES regulations until 60 days after publication in the

Federal Register of a notice of availability of the final document (44

FR 47063). EPA announced on March 20, 1980 the availability of the

draft report and provided a 45-day comment period (45 FR 17997), which

subsequently was extended twice, resulting in a 120-day comment period

on the report. Based on public comments on the draft report and further

discussion with industry, the Agency revised the draft report and

published this guidance document.

Final BMP Regulation

RESERVED

4

Final Guidance Document

RESERVED

5

SECTION II

USE OF THE GUIDANCE DOCUMENT

This document should be used for guidance in developing BMP plans.

The document is not intended to specify site-specific or pollutant-

specific BMPs. As its name suggests, the NPDES Best Management

Practices Guidance Document is to be considered guidance by NPDES

permitting authorities, compliance officers, permit applicants and

permittees and should be used in a flexible manner in the formulation of

BMP plans. Consequently, the document identifies elements of each

specific requirement that should be considered in the development of the

BMP plan, but does not require that each element be included in every

facility's BMP plan.

In utilizing this document to develop a BMP plan, the

applicant/permittee is encouraged to use the most cost-effective and

innovative techniques to fit the particular facility or circumstances.

The format and content of a BMP plan may vary from site to site and

industry to industry, depending upon the specific situation. In

addition, an applicant/permittee may add, delete, or modify the elements

of the specific requirements presented in the document where equivalent

results can be attained.

If an applicant/permittee needs assistance to develop a BMP plan,

he/she may contact the appropriate permit issuing authority for advice.

The permitting authority, as necessary, may seek assistance from the

Technical Program Development Section of the NPDES Technical Support

Branch in Washington, D.C.

6

SECTION III

BMP PLANS

Scope

The activities which are associated with or ancillary to the

industrial manufacturing or treatment process are subject to BMPs. For

brevity, all such activities are referred to as "ancillary sources".

The ancillary sources at the plant should be examined to determine if

there is a reasonable potential for equipment failure (e.g., spillage or

leakage), natural conditions (e.g., plant sit runoff or drainage from

raw material storage), or other circumstances (e.g., sludge or waste

disposal) which should result in the discharge of a significant amount

of toxic pollutants or hazardous substances to receiving waters. The

ancillary sources are divided for discussion in this document into five

(5) categories: material storage areas; loading and unloading areas;

plant site runoff; in-plant transfer, process, and material handling

areas; and sludge and hazardous waste disposal areas.

Material storage areas include storage areas for toxic and

hazardous chemicals as raw materials, intermediates, final products or

by-products. Included are: liquid storage vessels that range in size

from large tanks to 55-gallon drums; dry storage in bags, piles, bins,

silos, and boxes; and gas storage in tanks and vessels.

Loading and unloading operations involve the transfer of materials

to and from trucks or railcars but not in-plant transfers. These

operations include pumping of liquids or gases from truck or railcar to

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a storage facility or vice versa, pneumatic transfer of dry chemicals to

or from the loading or unloading vehicle, transfer by mechanical

conveyor systems, and transfer of bags, boxes, drums, or other

containers from vehicles by fork-lift trucks or other materials handling

equipment.

Plant runoff is generated principally from rainfall on a plant

site. Runoff from material storage areas, in-plant transfer areas,

loading and unloading areas, and sludge disposal sites potentially could

become contaminated with toxic pollutants and hazardous substances.

Heavy metals from sludge disposal sites are of special concern.

Fallout, resulting from the plant air emissions which settle on the

plant site, may also contribute to contaminated runoff. Contaminated

runoff may reach a receiving body of water through overland flow,

drainage ditches, storm or noncontact cooling water sewers, or overflows

from combined sewer systems.

In-plant transfer areas, process areas, and material handling

areas encompass all in-plant transfer operations from raw material to

final product. Various operations could include: transfer of liquids

or gases by pipelines with appurtenances such as pumps, valves and

fittings; movement of bulk materials by mechanical conveyor-belt

systems; and fork-lift truck transport of bags, drums, and bins. All

transfer operations within the process area with a potential for release

of toxic pollutants and hazardous substances to other than the process

waste water system are addressed in this grouping.

Sludge and hazardous waste disposal areas are potential sources of

contamination of receiving waters. These operations include land-fills,

pits, ponds, lagoons, and deep-well injection sites.

8

Depending on the construction and operation of these sites there may be

a potential for leachate containing toxic pollutants or hazardous

substances to seep into the ground water, eventually reaching surface

waters, or for liquids to overflow to surface waters from these disposal

operations. BMP requirements are not intended to duplicate the

requirements of RCRA. Actions taken for compliance with RCRA may be

referenced in the BMP plan.

Minimum Requirements

BMPs may include some of the same practices used by industry for

pollution control, SPCC plans for oil and hazardous substances, safety

programs, fire protection, protection against loss of valuable raw

materials or products, insurance policy requirements or public

relations. The minimum requirements of a BMP plan are listed in Table 1

and are divided into two (2) categories: general requirements and

specific requirements.

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TABLE 1

Minimum Requirements of a BMP Plan

A. General Requirements

1. Name and location of facility

2. Statement of BMP policy and objectives

3. Review by plant manager

B. Specific Requirements

1. BMP Committee

2. Risk Identification and Assessment

3. Reporting of BMP Incidents

4. Materials Compatibility

5. Good Housekeeping

6. Preventive Maintenance

7. Inspections and Records

8. Security

9. Employee Training

10

General Requirements

The BMP plan should be organized and described in and orderly

narrative format and should be reviewed by the plant engineering staff

and plant manager. A description of the facility, including the plant

name, the type of plant, processes used, and the products manufactured

should be included in the BMP plan. A map showing the location of the

facility and the adjacent receiving waters also should be part of the

plan. Specific objectives for the control of toxic pollutants and

hazardous substances should be included in the statement of corporate

policy.

Specific Requirements

Each of the nine (9) specific requirements listed in Table 1

should be addressed in the BMP plan. The size and complexity of the BMP

plan will vary with the corporate environmental policy, size,

complexity, and location of the facility, among other factors. It is

anticipated that the length and detail of the BMP plan will be

commensurate with the quantity of toxic and hazardous chemicals onsite

and their opportunity for discharge. A fundamental concept of the BMP

plan is determining the potential for toxic and hazardous chemicals to

reach receiving waters and taking appropriate preventive measures.

Discussions of the specific requirements are presented on the

following pages. Each specific requirement contains important elements

that should be considered in developing a BMP plan. All elements may

not be applicable to all facilities. Elements should be added, deleted

or modified to fit the needs of a particular facility. Permittees are

encouraged to use innovative techniques to achieve equivalent results.

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1. BMP Committee

The BMP Committee is that group of individuals within the plant

organization which is responsible for developing the BMP plan and

assisting the plant management in its implementations, maintenance and

updating. Thus, the Committee's functions are similar to those of a

plant fire prevention or safety committee.

The scope of activities and responsibilities of the "BMP

Committee" should include all aspects of the facility's BMP plan, such

as identification of toxic and hazardous materials handled in the plant;

identification of potential spill sources; establishment of incident

reporting procedures; development of BMP inspection and records

procedures; review of environmental incidents to determine and implement

necessary changes to the BMP plan; coordination of plant incident

response, cleanup and notification of authorities; establishment of BMP

training for plant personnel; and aiding interdepartmental coordination

in carrying out the BMP plan.

Other Committee duties could include review of new construction

and changes in processes and procedures at the facility relative to

spill prevention and control. The Committee can also periodically

evaluate the effectiveness of the overall BMP plan and make

recommendations to management on BMP-related matters.

Plant management has overall responsibility for the BMP plan. The

plan should contain a clear statement of the management's policies and

responsibilities related to BMPs. Authority and responsibility for

immediate action in the event of a spill should be clearly established

and documented in the BMP plan, with the Committee indirectly involved

in that responsibility.

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The Committee should advise management on the technical aspects of

environmental incident control, but should not impede the decision-

making process for preventing or mitigating spills and incidents.

The size and composition of the BMP Committee should be

appropriate to the size and complexity of the plant and the specific

toxic and hazardous chemicals handled at the plant. Facility personnel

knowledgeable in spill control and waste treatment such as environmental

specialists, production foreman, safety and health specialists, and

treatment plant supervisor should be included. In some small plants,

the Committee might consist of the one manager or engineer assigned

responsibility for environmental control. For very small facilities,

the Committee function might even have to be fulfilled by competent

engineers or managers from the corporate staff or the nearest large

plant.

A list of personnel on the BMP Committee should be included in the

BMP plan. The list should have the office and home telephone numbers of

the Committee members and the names and phone numbers of backup or

alternate people.

Elements of the "BMP Committee", listed below, should be

considered in developing a BMP plan:

m Inclusion of facility personnel knowledgeable in spill control,

safety and health, and waste treatment such as environmental

specialists, production foreman, occupational safety and health

specialists, and treatment plant supervisor.

m Responsibility for

- providing assistance to plant management for developing a BMP

plan,

13

- providing assistance to plant management in implementing,

maintaining, and updating the BMP plan,

- identifying toxic and hazardous substances,

- identifying potential spill sources,

- establishing BMP incident reporting procedures,

- developing BMP inspections and records procedures,

- reviewing environmental incidents,

- coordinating plant incident response, cleanup and

notification procedures,

- establishing BMP training for plant and contractor personnel,

- providing assistance for interdepartmental coordination in

carrying out the BMP plan,

- reviewing new construction and changes in processes and

procedures,

- evaluating the effectiveness of the BMP plan,

- making recommendations to management in support of corporate

policy on BMP-related matters.

2. Risk Identification and Assessment

The areas of the plant subject to BMP requirements should be

identified by the BMP Committee, plant engineering group, environmental

engineer, or others in the plant. Each such area should be examined for

the potential risks for discharges to receiving waters of toxic

pollutants or hazardous substances from ancillary sources. Any existing

physical means (dikes, diversion ditches, etc.) of controlling such

discharges also should be identified.

14

The areas described above should be clearly indicated on a plant

plot plan or drawing. A simplified materials flowsheet showing major

process operations can be used to indicate the direction and quantity of

materials flowing from one area to another. The direction of flow of

potential spills and surface runoff could also be estimated based on

site topography and indicated on the plant site drawings. Dry chemicals

which are toxic pollutants or hazardous substances should be evaluated

if they have the potential to reach navigable waters in significant

quantities via rainfall runoff, for example.

A hazardous substance and toxic chemical (materials) inventory

should be developed as a part of the "Risk Identification and

Assessment". The detail of the materials inventory should be

proportionate to the quantity of toxic pollutants and hazardous

substances on site and their potential for reaching the receiving

waters. For example:

(1) The plant has determined that materials stored in bulk

quantities at a tank farm have a high potential for reaching

the receiving waters in the event of structural failure or

overfills. Therefore, the materials inventory for the tank

farm should be detailed, and should provide the identity,

quantities, and locations of each material.

(2) The plant has determined that materials stored in small

quantities at the research laboratory have a low potential

for reaching the receiving waters. Therefore, the materials

inventory for the laboratory could be minimally detailed, and

may not include the identity, quantity, or location of each

material but might include an estimate of the total quantity

15

of toxic and hazardous materials stored and would provide the

location of the laboratory. The rationale for the "low risk"

nature of the laboratory would be provided in this part of

the BMP plan.

(3) The plant has determined that materials used in a batch

operation in the manufacturing process have a high potential

for reaching the receiving water. The plant supplies a

variety of products through the batch operation process to

accommodate fluctuations in public demand. Consequently, the

materials used for the batch process vary from week to week,

oftentimes unexpectedly. Therefore, the materials inventory

for the batch operation should be detailed but remain

flexible. The inventory might include the identification of

each material expected for use, and the maximum quantity of

material that the batch process can handle. The materials

inventory could be updated to include any material

substitutions unanticipated at the time of the original

inventory.

The examples above illustrate the flexibility of the materials

inventory. A materials inventory should be part of the "Risk

Identification and Assessment" of every BMP plan but the detail of the

inventory will vary with the size and complexity of the plant, the

quantities of toxic and hazardous chemicals on site and the potential

for incidents reaching receiving waters as well as the detail needed for

the materials inventory requires sound engineering judgment.

16

The materials inventory and other useful technical information

should be made available to the BMP Committee but may require separate

filing from the BMP plan documents to protect proprietary information or

trade secrets. This data may include physical, chemical, toxicological

and health information (e.g., technical bulletins or material safety

data sheets) on the toxic pollutants and hazardous substances handled;

the quantities involved in various operations or ancillary sources; and

the prevention, containment, mitigation, and cleanup techniques that are

used or would be used in the event of a discharge.

Materials planned for future use in the plant should be evaluated

for their potential to be discharged in significant amounts to receiving

waters. Where the potential is high, the same type of technical data

described above should be obtained.

Elements of "Risk Identification and Assessment", listed below,

should be considered in developing a BMP plan:

m Identification of areas of the plant subject to BMP

requirements.

m Examination of identified areas for potential risks of BMP

incidents reaching receiving waters.

m Identification of existing site-specific or pollutant-

specific containment measures.

m Plant plot plans or drawings that clearly label the

identified areas.

m Simplified flowsheet(s) of the major process operations.

m Estimation of the direction of flow of potential discharges

toward navigable waters.

17

m Evaluation of the potential for materials planned for future

use to be discharged to receiving waters in significant

amounts.

m Materials inventory system tailored to the need of the

particular facility.

m Physical, chemical, toxicological, and health information on

the toxic and hazardous chemicals on-site.

3. Reporting of BMP Incidents

A BMP incident reporting system is used to keep records of

incidents such as spills, leaks, runoff and other improper discharges

for th purpose of minimizing recurrence, expediting mitigation or

cleanup activities, and complying with legal requirements. Reporting

procedures defined by the BMP Committee should include: notification of

a discharge to appropriate plant personnel to initiate immediate action;

formal written reports for review and evaluation by management of the

BMP incident and revisions to the BMP plan; and notification as required

by law to governmental and environmental agencies in the event that a

spill or other reportable discharge reaches the surface waters.

The reporting system should designate the avenues of reporting and

the responsible company and government officials to whom the incidents

would be reported. A list of names, office telephone numbers, and

residence telephone numbers of key employees in the order of

responsibility should be utilized when necessary for immediate reporting

of BMP incidents to plant management for implementation of emergency

response plans.

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A communications system should be designated and available for

notification of an impending or actual BMP incident. Reliable

communications with the person or persons directly responsible would

expedite immediate action and countermeasures to prevent incidents or to

contain and mitigate discharged chemicals. Such a communication system

could include telephone or radio contact between transfer operation, and

alarm systems that would signal the location of an incident. Provisions

to maintain communication in the event of a power failure should be

addressed.

Written reports on all BMP incidents should be submitted to the

plant's BMP Committee and plant management for review. Written reports

should include the date and time of the discharge, weather conditions,

nature of the materials involved, duration, volume, cause, environmental

problems, countermeasures taken, people and agencies notified, and

recommended revisions, as appropriate, to the BMP plan, operating

procedures and/or equipment to prevent recurrence.

Procedures and key data should be outlined for necessary reporting

of BMP incidents to federal, state, and local regulatory authorities.

In some circumstances, voluntary reporting to authorities such as

municipal sewage treatment works, drinking water treatment plants, and

fish and wildlife commissions may be desirable. The plant individuals

responsible for notification should be listed. Pertinent telephone

numbers should be listed for those individuals in the plant and those in

the agencies to be notified. The phone numbers should be reviewed

periodically for accuracy and might actually be used in the course of a

"spill drill".

19

Elements of "Reporting of BMP Incidents", listed below, should be

considered in developing a BMP plan:

m Maintenance of records of incidents through formal reports

for internal review.

m Notification as required by law to governmental and

environmental agencies should an incident occur.

m Procedures for notifying the appropriate plant personnel, and

taking preventive or mitigating actions.

m Identification of responsible company and government

officials.

m A list of names, office telephone extensions, and residence

telephone numbers of key personnel.

m A communications system for reporting incidents in-plant

(i.e., telephone, alarms, radio, etc.).

4. Materials Compatibility

Incompatibility of materials can cause equipment failure resulting

from corrosion, fire or explosion. Equipment failure can be prevented

by ensuring that the materials of construction for containers handling

hazardous substances or toxic pollutants are compatible with the

containers' contents and surrounding environment.

Materials compatibility encompasses three (3) aspects:

Compatibility of the chemicals being handled with the materials of

construction of the container, compatibility of different chemicals upon

mixing in a container, and compatibility of the container with its

environment.

20

The specific requirement of "Materials Compatibility" in the BMP plan

should provide procedures to address these three (3) aspects in the

design and operation of the equipment on site handling toxic and

hazardous materials.

The BMP documentation on materials compatibility should recognize

the engineering practices already used in the plant, and should

summarize these existing practices with regard to corrosion and other

aspects of material compatibility. Specific consideration should be

given to procedures and practices delineating the mixing of chemicals

and the prohibition of mixing of incompatible chemicals which might

result in fire, explosion or unusual corrosion. Thorough cleaning of

storage vessels and equipment before being used for another chemical

should be standard practice to ensure that there is no residual of a

chemical that is incompatible with the second, or later, chemical to be

used. Coatings or cathodic protection should be considered for

protecting a buried pipeline or storage tank from corrosion.

Where applicable, material testing procedures should be described.

Proposed substitutions for currently used toxic or hazardous chemicals

should be studied to determine whether the construction materials of the

existing containers are compatible with the proposed new conditions.

The procedures utilized by the plant or an outside contractor to perform

the materials compatibility study should be documented. Materials

compatibility aspects of waste disposal which are covered by the RCRA

hazardous waste regulations should be referenced in the BMP plan.

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Elements of "Materials Compatibility", listed below, should be

considered in developing a BMP plan:

m Evaluation of process changes or revisions for materials

compatibility.

m Incorporation of existing engineering practices for materials

of construction, corrosion, and other aspects of materials

compatibility.

m Evaluation of procedures for mixing of chemicals and of

possible incompatibility with other chemicals present.

m Cleansing of vessels and transfer lines before they are used

for another chemical.

m Use of proper coatings and cathodic protection on buried

pipelines if required to prevent failure due to external

corrosion.

5. Good Housekeeping

Good housekeeping is essentially the maintenance of a clean,

orderly work environment and contributes to the overall facility

pollution control effort. Periodic training of employees on

housekeeping techniques for those plant areas where the potential exists

for BMP incidents reduces the possibility of incidents caused by

mishandling of chemicals or equipment.

Examples of good housekeeping include neat and orderly storage of

bags, drums and piles of chemicals; prompt cleanup of spilled liquids to

prevent significant run-off to navigable waters; sweeping, vacuuming or

other cleanup of accumulations of dry chemicals as necessary to prevent

22

them from reaching receiving waters; and provisions for storage of

containers or drums to keep them from protruding into open walkways or

pathways.

Maintaining employee interest in good housekeeping is a vital part

of the BMP plan. Methods for maintaining good housekeeping goals could

include regular housekeeping inspections by supervisors and higher

management; discussions of housekeeping at meetings; and publicity

through posters, suggestion boxes, bulletin boards, slogans, incentive

programs and employee publications.

Elements of "Good Housekeeping", listed below, should be

considered in developing a BMP plan:

m Neat and orderly storage of chemicals.

m Prompt removal of spillage.

m Maintenance of dry and clean floors by use of brooms, vacuum

cleaners, etc.

m Proper pathways and walkways and no containers and drums that

protrude onto walkways.

m Minimum accumulation of liquid and solid chemicals on the

ground or floor.

m Stimulation of employee interest in good housekeeping.

6. Preventive Maintenance

An effective preventive maintenance (PM) program is important to

prevent BMP incidents. A PM program involves inspection and testing of

plant equipment and systems to uncover conditions which could cause

breakdowns or failures with resultant significant discharges of

chemicals to receiving waters. The program should prevent breakdowns

23

and failures by adjustment, repair or replacement of items. A PM

program should include a suitable records system for scheduling tests

and inspections, recording test results, and facilitating corrective

action. Most plants have existing PM programs which provide a degree of

environmental protection. It is not the intent of the BMP plan to

require development of a redundant PM program. Instead, the objective

is to have qualified plant personnel (e.g., BMP Committee, maintenance

foreman, environmental engineer) evaluate the existing plant PM program

and recommend to management those changes, if any, needed to address BMP

requirements.

A good PM program should include the following: (1)

identification of equipment or systems to which the PM program should

apply (2) periodic inspections or tests of identified equipment and

systems; (3) appropriate adjustment, repair, or replacement of items;

and (4) maintenance of complete PM records on the applicable equipment

and systems.

The BMP plan documentation of PM may include a list of procedures,

examples of record keeping, a list of the principal systems to which the

PM program is applicable, and directions for obtaining the records for

any particular system included or referenced in the BMP plan. In

general, it will be adequate to reference in the BMP plan the scope and

location of existing PM procedures and records applicable to the PM

specific requirement.

Elements of "Preventive Maintenance", listed below, should be

considered in developing a BMP plan:

m Identification of equipment and systems to which the PM

program should apply.

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m Periodic inspections of identified equipment and systems.

m Periodic testing of such equipment and systems.

m Appropriate adjustment, repair, or replacement of parts.

m Maintenance of complete PM records on the applicable

equipment and systems.

7. Inspections and Records

The purpose of the inspection and records system is to detect

actual or potential BMP incidents. The BMP plan should include written

inspection procedures and optimum time intervals between inspections.

Records to show the completion date and results of each inspection

should be signed by the appropriate supervisor and maintained for a

period of three (3) years. A tracking (follow-up) procedure should be

instituted to assure that adequate response and corrective action have

been taken. The record keeping portion of this system can be combined

with the existing spill reporting system in the plant.

While plant security and other personnel may frequently and

routinely inspect the plant for BMP incidents, these people are not

necessarily capable of assessing the potential for such incidents. Thus

certain inspections should be assigned to designated qualified

individuals, such as maintenance personnel or environmental engineering

staff.

The inspection and records system should include those equipment

and plant areas identified in the "Risk Identification and Assessment"

portion of the BMP plan as having the potential for significant

discharges. To determine the inspection frequency and inspection

procedures, competent environmental personnel should evaluate the causes

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of previous incidents, and assess the probable risks for incident

occurrence. Furthermore, the nature of chemicals handled, materials of

construction, and site-specific factors including age, inspection

techniques and cost effectiveness should be considered.

Qualified plant personnel should be identified to inspect

designated equipment and plant areas. Typical inspections should

include examination of pipes, pumps, tanks, supports, foundations,

dikes, and drainage ditches. Records should be kept to determine if

changes in preventive maintenance or good housekeeping procedures are

necessary. Each of the ancillary sources should have "Inspection and

Records" programs designed to meet the needs of the particular facility.

Material storage areas for dry chemicals should be inspected for

evidence of, or the potential for, windblowing which might result in

significant discharges. Liquid storage areas should be inspected for

leaks in tanks, for corrosion of tanks, for deterioration of foundations

or supports, and for closure of drain valves in containment facilities.

Inspections could include the examination of seams, rivets, nozzle

connections, valves, and connecting pipelines. Storage tanks should be

inspected for evidence of corrosion, pitting, cracks, abnormalities, and

deformation and such evidence should then be evaluated.

For in-plant transfer and materials handling of liquids,

inspections should include visual examination for evidence of

deterioration of pipelines, pumps, valves, seals and fittings. The

general condition of items such as flange and expansion joints, pipeline

supports, locking valves, catch or drip pans, and metal surfaces also

should be assessed.

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For loading and unloading operations, inspections during transfer

of materials would permit immediate response if an incident occurred.

The conditions of pipelines, pumps, valves, and fittings for liquid

transfer systems and pneumatic conveying systems used for transferring

dry chemicals should be inspected. Inspections (together with

monitoring) should be used to ensure that the transfer of material is

complete before flexible or fixed transfer lines are disconnected prior

to vehicular departure. Before any tank car or tank truck is filled,

the lower-most drain valve and all outlets of such vehicles should be

closely examined for evidence of leakage and, if necessary, tightened,

adjusted, or replaced. Before departure, all tank cars or tank trucks

should be closely examined to ensure that all transfer lines are

disconnected and that there is no evidence of leakage from any outlet.

For plant runoff, inspections should be used for examining the

integrity of the storm water collection system and the diversion or

overflow structures, and for ensuring the drain valves and pumps for

diked areas are properly closed. The plant sewer and storm sewer system

should be periodically surveyed to ensure that toxic and hazardous

pollutants are not discharged in significant amounts. Inspections also

should include diked areas to ensure that hazardous and toxic chemicals

are not discharged form inside diked areas to waterways. Any liquid,

including rainwater, should be examined, and where necessary, analyzed,

before being released from the diked areas to a receiving water.

For sludge and hazardous waste disposal sites, visual inspections

should include examinations for leaks, seepage, and overflows from land

disposal sites such as pits, ponds, lagoons, and landfill. Other

procedures and inspection techniques should be considered on a site-

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specific basis. Any inspections made or records kept to comply with

RCRA may be included in the BMP plan by reference.

Elements of "Inspection and Records", listed below, should be

considered in developing a BMP plan:

m Inspection of:

storage facilities,

transfer pipelines,

loading and unloading areas,

pipes, pumps, valves, and fittings,

tank corrosion (internal and external),

windblowing of dry chemicals,

tank support or foundation deterioration,

seams along drainage ditches and old tanks,

deterioration of primary or secondary containment,

housekeeping,

drain valves on tanks,

damage to shipping containers,

conveying systems for dry chemicals,

integrity of storm water collection system,

leaks, seepage, and overflows from sludge and waste

disposal sites.

m Records of all inspections

m Tracking procedures to assure adequate response and

corrective actions have been taken when inspections reveal

deficiencies.

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8. Security

A security system is needed to prevent accidental or intentional

entry to a plant which might result in vandalism, theft, sabotage or

other improper or illegal use of plant facilities that could possibly

cause a BMP incident. Most plants have security systems to prevent

unauthorized entry leading to theft, vandalism, sabotage and the like.

The BMP plan should describe those portions of the existing security

system which ensure that the pertinent chemicals are not discharged to

receiving waters in significant quantities. Documentation of the

security system may require separate filing from the BMP plan documents

to prevent unauthorized individuals from gaining access to confidential

information.

The BMP Committee, plant security manager, plant engineer or other

qualified plant personnel should evaluate the coverage of the existing

security system for those areas of the plant and the equipment

identified by the "Risk Identification and Assessment" specific

requirement as having the potential for significant discharges. They

should recommend to plant management any changes necessary to improve

the security system.

Examples of security measures include: routine patrol of the

plant by security guards in vehicles or on foot; fencing to prevent

intruders from entering the plant site; good lighting; vehicular traffic

control; a guardhouse or main entrance gate, where all visitors are

required to sign in and obtain a visitor's pass; secure or locked

entrances to the plant; locks on certain valves or pump starters; and

television surveillance of appropriate plant sites, such as plant

entrance, and loading and unloading areas.

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Whenever possible, security personnel should be instructed to

observe leaks from tanks, valves, or pipelines while patrolling the

plant and also be informed of the procedures to follow when a spill or

other discharge is detected. Many plants use contractor or plant

security personnel who may not be qualified or may not have time to

carry out such surveillance. In such cases, the surveillance can be

incorporated in the "Inspection and Records" specific requirement and

should be conducted by production or environmental staff.

Elements of "Security", listed below, should be considered in

developing a BMP plan:

m Routine patrols of plant by security personnel.

m Fencing.

m Good lighting.

m Vehicular traffic control.

m Controlled access at guardhouse or main entrance gate.

m Visitor passes.

m Locked entrances.

m Locks on certain drain valves and pump starters.

m Television monitoring.

9. Employee Training

Employee training programs should instill in personnel, at all

levels or responsibility, a complete understanding of the BMP plan, the

processes and materials with which they are working, the safety hazards,

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the practices for preventing discharges, and the procedures for

responding properly and rapidly to toxic and hazardous materials

incidents. Employee training meetings should be conducted at least

annually to assure adequate understanding of the objectives of the BMP

plan and the individual responsibilities of each employee. Typically,

these meetings could be a part of routine employee meetings for safety

or fire protection. Such meetings should highlight previous spill

events or failures, malfunctioning equipment components, and recently

developed BMP precautionary measures. Training sessions should review

the BMP plan and associated procedures. Just as fire drills are used to

improve an employee's reaction to a fire emergency, spill or

environmental incident drills may serve to improve the employee's

reactions to BMP incidents. Plants are encouraged to conduct spill

drills on a quarterly or semi-annual basis. Spill drills serve to

evaluate the employees' knowledge of BMP-related procedures and are a

fundamental part of employee training.

Of particular importance is the strong commitment and periodic

input from top management to the employee training program to create the

necessary climate of concern for a successful program. A plant manager

might accomplish more in a brief, face-to-face appearance than an

elaborate, impersonal training program would accomplish.

Adequate training in a particular job and process operation is

essential for understanding potential discharge problems. Knowledge of

specific manufacturing operations and how discharges could occur, or

have occurred in the past, is important in reducing human error that can

lead to BMP incidents.

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The training program also should be aimed at making employees

aware of the protocol used to report discharges and notifying the people

responsible for response so that immediate countermeasures can be

initiated. In addition, personnel involved in BMP-incident response

would be trained to use cleanup materials such as sorbents, gelling

agents, foams, and neutralizing agents. As appropriate, they should be

educated in safety precautions, in the side effects of the chemicals

they are working with, and in possible chemical reactions. Operating

manuals and standard procedures for process operations should include

appropriate sections on the BMP plan and the spill control program and

would be readily available for reference. Spill response drills,

suggestion boxes, posters, and incentive programs can be used to

motivate employees to be alert to the potential for discharges and to

their prevention.

The employee training program should include records of the

frequency, and names and position of the employees trained as well as

the lesson plans, subject material covered, and instructors' names and

positions. BMP-related training may be combined with other forms of

training, such as safety and fire prevention at the discretion of the

plant.

In addition to permanent personnel, contractors or temporary

personnel should be trained in procedures for preventing BMP incidents

since these individuals may be unfamiliar with the normal operating

procedures or location of equipment (pipelines, tanks, etc.) at the

facility. Adequate supervision of contractor maintenance personnel

should be provided to minimize the possibility of BMP incidents

resulting from damaging equipment such as buried pipelines.

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Elements of "Employee Training", listed below, should be

considered in developing the BMP plan:

m Meetings held at least annually to assure adequate

understanding of program goals and objectives.

m Environmental Incident (Spill) drills used at least

semiannually.

m Periodic input from management.

m Adequate training in particular job and process operation and

the effect on other operations.

m Transmission of knowledge of past incidents and causes.

m Making employees aware of BMP plan and incident reporting

procedures.

m Training in the use of sorbents, gelling agents, foams, and

neutralizing agents for cleanup or mitigation of incidents.

m Operating manuals and standard procedures.

m Making employees aware of health risks of chemicals handled

through both the plant's BMP plan and safety program.

m Motivating employees concerning incident prevention and

control.

m Records of the personnel who were trained, and of the dated,

instructors, subject matter, and lesson plans of the training

sessions.

m Training and supervision of contractors and temporary

personnel.

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